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Tax Foundation Comments on the Wyden, Warner, Brown Discussion Draft

Introduction Tax Foundation welcomes the opportunity to offer comments on the Wyden, Warner, Brown discussion draft on international taxation. Tax Foundation is a nonprofit think tank based in Washington, D.C., and our mission is to improve lives through tax policies that lead to greater economic growth and opportunity. We use the four principles of simplicity, […]

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Temporary Policies Complicate the Child Tax Credit’s Future

Over the next ten years, the structure of the Child Tax Credit (CTC) is scheduled to change, complicating efforts to extend enhanced Child Tax Credit benefits or reform the Child Tax Credit for the long-term. Rather than take an all-or-nothing approach or kick the can down the road by relying on temporary expansions, lawmakers could consider […]

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GILTI of Neglecting Losses

Sometimes the more you learn about a tax policy, the more it confuses you. Many times, the confusion lies between the intent of the policymakers and what really happens. Often, it’s when important issues were overlooked when the policy was being designed. Such is the case for U.S. companies that run losses on their domestic […]

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Expense Allocation: A Hidden Tax on Domestic Activities and Foreign Profits

The U.S. corporate tax code is a complicated behemoth, loaded with numerous arcane provisions—some of these providing special tax breaks, others imposing special tax penalties. Among the latter group, indirect expense allocation rules penalize domestic activities and impose a hidden surtax on foreign profits. While arcane, expense allocation rules are relevant to current debates because […]

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Analysis of Sen. Wyden’s Pass-through Deduction Proposal

Senator Ron Wyden (D-OR) recently introduced the Small Business Tax Fairness Act—the impact of which we modeled—to reform the Section 199A pass-through business deduction created in the Tax Cuts and Jobs Act (TCJA) of 2017. The provision currently allows taxpayers to deduct up to 20 percent of their qualified business income from their taxable income, […]

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Options for Reforming the Taxation of U.S. Multinationals

Key Findings We analyze four options for changing the taxation of U.S. muiltinationals: the full Biden administration proposal raises the federal corporate income tax liabilities of U.S. multinationals by $1.37 trillion over a decade; a partial version raises $580 billion; making GILTI consistent with Pillar 2 raises $137 billion; and a revenue-neutral option to fix […]

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Corporate Tax Revenue Forecasted as Robust following the 2017 Tax Reform

It appears that the recent dip in corporate tax collections, which the Biden administration has noted for concern and justification for increasing the corporate tax rate among other proposals to raise taxes on corporations, was largely due to temporary factors related to the pandemic rather than the Tax Cuts and Jobs Acts (TCJA) of 2017. […]

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Delaying R&D Amortization Costs Less but Generates Little Economic Benefit Compared to Full Cancellation

Starting next year, firms will need to amortize their research and development (R&D) expenses over five years rather than immediately deduct them from taxable income, a policy change designed to raise federal tax revenue in the short term. As policymakers decide on the future of this scheduled tax change, one option would be to delay […]

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Policymakers Offer Proposals to Fix Three Upcoming Tax Changes

Three upcoming tax law changes scheduled by the 2017 Tax Cuts and Jobs Act (TCJA) to help offset its revenue losses would be canceled by proposed legislation that would prevent the tax treatment of investment from worsening over the coming years. Three Upcoming Tax Increases on Investment Policy Timing Requirement to amortize R&D expenses over […]

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Expensing Is Infrastructure, Too

The Biden administration has suggested several tax increases for his infrastructure plan. Public infrastructure can help increase economic growth, but by raising taxes on private investment, the net effect on growth may be negative. However, tax options like retaining expensing for private R&D investment or making 100 percent bonus depreciation for equipment permanent would be […]